SARS has released binding private ruling 185, which deals
with the disposal of assets (including the equity shares held in various
subsidiaries) and liabilities (including contingent liabilities) from one
company to another company under section 42 of the Income Tax Act.
Section 240A of the Tax Administration Act, 2011 (as amended) requires that all tax practitioners register with a recognized controlling body before 1 July 2013. It is a criminal offense to not register with both a recognized controlling body and SARS.